Wolf v. Colorado
338 U.S. 25 (1949)
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Rule of Law:
The Fourteenth Amendment's Due Process Clause incorporates the Fourth Amendment's protection against unreasonable searches and seizures, making it applicable to the states, but it does not require state courts to exclude evidence obtained in violation of this protection.
Facts:
- Julius Wolf was a physician practicing in Denver, Colorado.
- Wolf was suspected by law enforcement of performing criminal abortions.
- A local deputy sheriff and an investigator from the district attorney's office went to Wolf's office without a search warrant.
- The officers seized Wolf's appointment books during their warrantless entry.
- The seized appointment books were subsequently introduced as evidence against Wolf at his trial for conspiracy to commit abortion.
Procedural Posture:
- The State of Colorado charged Wolf with conspiracy to perform abortions in a Colorado state trial court.
- At trial, the court admitted into evidence Wolf's appointment books that had been seized without a warrant.
- The jury convicted Wolf.
- Wolf, as appellant, appealed his conviction to the Supreme Court of Colorado, arguing the admission of the illegally seized evidence violated his constitutional rights.
- The Supreme Court of Colorado, as appellee, affirmed the conviction.
- The United States Supreme Court granted certiorari to review the judgment of the Colorado Supreme Court.
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Issue:
Does a state court conviction for a state crime violate the Due Process Clause of the Fourteenth Amendment if it is based on evidence that would be inadmissible in a federal court because it was obtained through an unreasonable search and seizure?
Opinions:
Majority - Justice Frankfurter
No, a state court conviction based on illegally seized evidence does not violate the Due Process Clause of the Fourteenth Amendment. While the core Fourth Amendment right to privacy against arbitrary police intrusion is fundamental and therefore incorporated against the states through the Due Process Clause, the exclusionary rule is a judicially created remedy, not a fundamental right itself. States are free to adopt other methods of enforcing the Fourth Amendment, such as civil trespass actions against offending officers or internal police discipline. The Court noted that a majority of states had rejected the exclusionary rule, and it refused to impose this single remedy on all states, respecting their ability to choose among various effective enforcement mechanisms.
Concurring - Justice Black
No, the conviction should be affirmed. Although the Fourth Amendment applies in its entirety to the states through the Fourteenth Amendment, the exclusionary rule is not a command of the Fourth Amendment itself. Instead, it is a judicially created rule of evidence established for federal courts. Because the exclusionary rule is not part of the constitutional amendment, it is not incorporated against the states and therefore is not binding on them.
Dissenting - Justice Murphy
Yes, the conviction violates due process and should be reversed. The only effective remedy for a violation of the Fourth Amendment is the exclusion of illegally obtained evidence, as all other suggested remedies are illusory and impractical. Civil suits are ineffective because damages are often minimal and officers may be judgment-proof, and internal police discipline is unreliable. The dissent argues that without the exclusionary rule, the Fourth Amendment right is unenforceable and meaningless in state criminal proceedings, which encourages 'lawlessness by officers of the law.'
Dissenting - Justice Douglas
Yes, the conviction should be reversed. The Fourth Amendment is fully applicable to the states, and without the exclusionary rule as an enforcement mechanism, the amendment would have no 'effective sanction.' The right to be free from unreasonable searches and seizures is rendered meaningless if the fruits of its violation can be used to secure a conviction.
Dissenting - Justice Rutledge
Yes, the conviction should be reversed. The Fourth Amendment's exclusionary sanction is an inseparable component of the right itself, not merely a rule of evidence. Because the court correctly holds that the substance of the Fourth Amendment is valid against the states, the essential sanction required to give it meaning must also apply. To hold otherwise reduces the Fourth Amendment to a 'dead letter' in state proceedings.
Analysis:
This decision established a bifurcated doctrine where a constitutional right (the Fourth Amendment's protection against unreasonable searches) was held to be binding on the states, but the primary remedy for its violation (the exclusionary rule) was not. This 'right without a remedy' approach created a major inconsistency, allowing state law enforcement to violate the Fourth Amendment without the consequence of evidence suppression in state courts. The decision reflected the Court's reluctance to impose federal procedural rules on state criminal justice systems, but its logic was ultimately deemed unworkable and was explicitly overturned twelve years later in Mapp v. Ohio (1961), which applied the exclusionary rule to the states.
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